Stop was justified, but it did not evolve into justification for a frisk

While defendant’s stop was based on [tenuous] reasonable suspicion, the officer’s detention thereafter was unreasonable because there was no showing of justification. Grandberry v. State, 289 Ga. App. 534, 658 S.E.2d 161 (2008):

Meanwhile, the police were detaining Grandberry based solely on the word of the complainant, whose identity could not be confirmed and whose reliability had become an issue. Under these circumstances, law enforcement’s detention of Grandberry for 40 minutes exceeded the scope of the brief investigatory stop authorized by Terry. See Schmidt, supra, 188 Ga. App. at 87; United States v. Dortch, 199 F.3d 193, 200 (II) (A) (5th Cir. 1999) (justification for suspect’s detention ceased when computer check came back negative, and the subsequent discovery of drugs following a canine search was the product of a Fourth Amendment violation).

School security officer had reasonable suspicion for a search at school based on defendant’s being under the influence the day before, and defendant was seen the next day on a security camera showing something to another student with a cupped hand. R.B. v. State, 975 So. 2d 546 (Fla. App. 3DCA 2008).*

Lack of CI’s track record did not void the search. There was independent verification, including from a controlled buy [which usually seals the deal]. State v. Jenkins, 178 Md. App. 156, 941 A.2d 517 (2008). (Comment: Moylan opinions are usually interesting to read, but this one gets a little ponderous. There seems to be a little venting going on here, too.)